WS-5670_20028_G_SLR_20220325

(Revised October 2018)
RECOMMENDATION OF SITE FOR STATE LEAD CLEANUP
Incident Name: Colfax Oil Company/ Colfax Service
Station UST #: WS-5670/WS-5520 Incident #: 20028/19240
Site Address: 9420 & 9422 W. Market Street Site Priority Risk/Rank: H410D/H570
D
City: Colfax County: Guilford
Current Landowner: Hardin Oil Company, Inc. Address: PO Box 4265, Greensboro, NC 27404
Recommended by: Jordan Lerew Region: Guilf Co. Date of Last Site Visit:
Linda Estkowski WSRO
Step 1: Private/Public water supply well within 1000’ ☒ yes ☐ no
Has a water supply been contaminated? ☒ yes ☐ no
Has alternate water been provided? ☒ yes ☐ no
Step 2: This incident is recommended for State Lead Cleanup because (check all that apply):
☐ The RO has not been able to positively identify the source(s) of contamination
☐ The RO has not been able to positively identify the RP
☒ The RO has positively identified the source(s) but RP cannot be located, or is deceased/dissolved
☐ The RP has been identified but refuses to comply with investigative requirements
☐ The RP has been identified but claims financial hardship or bankruptcy
☐ The RO is continuing its investigation of sources and RPs, but immediate action is necessary to protect
human health and the environment. (Additional detail in comments below.)
Step 3: Attach a statement documenting or supporting the site risk determination (RRA Form) based upon a confirmed
UST release of petroleum to soil and/or groundwater.
Step 4: Attach cover memo with a summary of site history and chronology of events, including RO actions taken to date.
Step 5: Attach or provide a link to scans of the entire original Regional Office file, and be sure it includes:
☒ 24-Hour Release and UST Leak Reporting Form (Form 61) and ranking forms
☒ Topographic map with site location clearly identified
☒ NORRs, NOVs, and any other correspondence issued and received
☒ Alternate water requests and any information on available water sources
☒ Telephone logs and any supplemental information
Step 6: Check all that apply for any UST located at the site:
☐ UST is a heating oil tank 100 gallons or less
☐ UST is a heating oil tank greater than 1100 gallons for four or fewer households
☐ UST is a farm or residential, 1100 gallons or less of motor fuel for non-commercial purposes
☐ The UST is a non-regulated, commercial UST
☒ The UST is a regulated, commercial UST
Comments: The RP for the two release incidents on this property is Hardin Oil Company, Inc. The assessment of the
two incidents was combined and to be completed concurrently. Assessment of #20028 shows a
groundwater plume that has been reduced in horizontal extent and magnitude. Assessment of #19240
was stalled since the RP was unwilling to reinstall monitoring wells that were destroyed by the NCDOT
during the widening of W. Market St. The horizontal extent of the release is unknown due to the
missing monitoring wells and inability to access offsite area to the south due to the presence of Norfolk
Southern railroad tracks. The consultant states that a diabase dike crosses the property and is having an
impact on groundwater flow direction, plume geometry, vertical migration, and recovery efforts.
Contamination of a water supply well (8723 Sherfield Rd) was attributed to incident #19240 however
current assessment work does not show undeniable evidence. A POE system was installed on the well
and is being maintained/sampled by the Bernard Allen Fund. RAMCO Fabricators, Inc. (EPA ID:
(Revised October 2018)
NCD986171494) is located on the property to the south and the release incident is being managed by
the hazardous waste section.

Facility 00-0-0000009519 - The following tanks were removed on 3/20/1999 (TIMS): Two 2K gas, one 3K
gas, one 8K gas, one 550-gal. oil, new/used mix.

Facility 00-0-0000009524 – The following tanks were removed on 3/9/1999 (TIMS): One 550 gal. gas,
one 550 gal. kerosene, one 550 gal. heating oil/fuel.

RP, Hardin Oil Company, Inc., is dissolved.

Linda Estkowski

03/16/2022
Interim Regional Supervisor Signature Date
Attachment: Incident File ☒

March 15, 2022
TO: Wayne Randolph, Trust Fund Branch Head, UST Section, Raleigh Central Office
THROUGH: Carin Lee Kromm, L.G., Interim Corrective Action Branch Head, UST Section, Raleigh Central Office
THROUGH: Linda Estkowski, Interim UST Section Regional Supervisor, Winston-Salem Office FROM: Jordan Lerew, Toxic & Health Hazard Specialist, Department of Health and Human Services, Guilford County SUBJECT: State Lead Request Incident Name: Colfax Oil Company & Colfax Service Station Incident #: 20028 / 19240 Facility ID: 00-0-0000009524 / 00-0-0000009519
Address: 9420 & 9422 W. Market Street, Colfax, NC Site Priority Risk/Rank: H410D / H570D Release Discovery Date: March 9, 1999 / November 12, 1998
RP: Hardin Oil Company, Inc. Current Landowner: Hardin Oil Company, Inc. Landowner Mailing Address: PO Box 4265, Greensboro, NC 27404
Landowner at Time of Release Discovery: Hardin Oil Company, Inc. Deed During Time of Release Discovery Book/Page: 2337/0429 (attached) Most Recent Deed Book/Page (same as deed at release discovery): 2337/0429 (attached) Reason(s) for State Lead Request Hardin Oil Company, Inc. dissolved on December 20, 2021 (attached).
Risk The risk ranking for #20028 is H410D due to the presence of nearby sole source supply wells. The risk ranking for #19240 is H570D due to the presence of nearby sole source supply wells and contamination of one supply well on Sherfield Rd being attributed to this release. Chronology of Incidents for #19240 and #20028 Independently and Concurrently
Release Incident #19240 (only) Circa 1939: Two 2,000-gal gasoline USTs were in use by Mr. Ira Potts, the property owner at the time. The property was operated as a fuel retail and service station.
8/16/1967: Hardin Oil Company, Inc. purchased the property from Ira Potts.
11/12/1998: A phone call was placed to the RO followed by a Leak Reporting form stating that contaminated soil was encountered by a utility crew installing water lines along W. Market St.

3/16/1999: One 8,000-gal, one 3,000-gal, and two 2,000-gal gasoline USTs were closed by removal along with one 550-gal waste oil UST and associated product lines and dispensers.
8/5/1999: The RO received the UST closure report. The closure report states that one closure soil sample collected from beneath the western dispenser island contained a TPH GRO concentration greater than the 10mg/kg action limit. No additional violations were reported for the remaining closure soil samples. Due to the limited nature of the release, 71.44 tons of contaminated soil was excavated. No limit of excavation soil samples were collected. It is unknown if the excavation was successful at fully remediating the source area. 8/10/1999: NORR for the completion of either a Soil Contamination Report to document soil quality at the end of the excavation or the completion of a Limited Site Assessment if soil quality wasn’t documented.
11/21/2000: NORR sent, requesting the completion of a CSA. 6/22/2004: ExxonMobil was issued a NORR for the completion of a CSA in regard to the release of a
second set of tanks on the Colfax Service Station portion of the property. These tanks were the ones operated by Ira Potts in the 1940ss-50’s.
9/21/2004: The site was given a risk ranking and abatement score of H370D. 9/27/2004: ExxonMobil submitted, to the RO, a rebuttal letter to the June 22, 2004 NORR stating that they have no record of ownership for the two orphaned USTs and typically the company would install and transfer ownership to the user of the tanks. They also state that there is no reason to complete a duplicate CSA as Hardin Oil Company, Inc. was already in the process of completing a CSA. 6/21/2006: The site’s RRA was increased to H570D due to the detected petroleum-type contamination of the Pyrtle supply well on Sherfield Rd. 6/27/2006: A NORR was issued to ExxonMobil for a pre-approval form.
2/27/2007: A NOV was issued to ExxonMobil for failure to submit a CAP. 3/13/2007: ExxonMobil submitted a response to the NOV stating they stand by their original rebuttal letter submitted on 9/27/2004 and will not be completing a CAP.
All future work is combined with UST Incident #20028 Release Incident #20028 (only) 3/9/1999: Colfax Oil Company closed four USTs, dispensers, and piping by removal. A Pollution Incident/ UST Leak Reporting Form was submitted to document release. 5/6/1999: RP submitted an UST Closure Report for USTs located on Colfax Oil Company property. Closure soil sample results show TPH action limit exceedances in samples collected from beneath the 1,000-gal and two of the three 550-gal USTs. The highest reported TPH concentrations were GRO at 758mg/kg and DRO at 2,780 mg/kg. According to the maps in the report, two ASTs were also located in the area of the closed USTs. The report makes no mention of the closure of the ASTs or of any potential of a release.

5/11/1999: NORR sent, requesting completion of a LSA.
9/21/2004: The release incident was given a RRA of H410D. Release Incidents #19240 & #20028 (combined) 9/15/2000: Received an LSA, completed to satisfy the NORRs for both release incidents on the property. A total of 25 private supply wells were identified within a 1,000 ft radius. Monitoring wells installed during this phase of work included 4 type II wells and 1 type III well. Free product was observed in MW1 during the installation of the adjacent type III well. Monitoring wells MW1 and MW1-D were installed into a diabase dike. 11/21/2000: NORR sent, requesting the completion of a CSA.
12/18/2001: NOV issued for failure to submit a CSA.
6/18/2002: NOV issued for failure to submit a CSA. 9/25/2002: Well construction permit issued for offsite well installation.
1/7/2003: NOV issued for failure to submit CSA. 1/21/2003: RP’s consultant submitted request for 45-day extension on CSA. 3/23/2003: Guilford County Environmental Health received a copy of a property owner notification letter from NCDEQ Hazardous Waste Section regarding the discovery of contamination impacting two private supply wells on Sherfield Rd. The supply well sampling was conducted to investigate drinking water quality downgradient of RAMCO Fabricators facility which is located between the Colfax Oil Company UST incidents and Sherfield Rd properties.
4/16/2004: Recommendation for Enforcement Action letter sent to RP for failure to submit a CSA 4/16/2004: The RP submitted a CSA with assessment actions encompassing both release incidents on the
property. The report states the number of supply wells was reduced to 23 from the 25 counted in the LSA. Free product has been persistently present in monitoring well MW1. This monitoring well was installed to investigate the Colfax Oil Company release incident. The greatest levels of dissolved phase contamination
were detected in monitoring well MW7 (benzene 26,000ppb), installed to assess the Colfax Service Station release incident. 4/27/2004: NORR sent, requesting the completion of a CAP for both incidents in one report. 6/24/2004: Tank closure report submitted for two 2,000-gallon USTs removed from the south side of the Colfax Service Station building. Based upon historical property information, these tanks were associated with Ira Potts (previous property owner) and operated from the 1930’s – 1950’s. Upon removal, each tank was found to be filled with sand and contain a puncture hole in the bottom, opposite each’s fill port. The report states, “According to a former store operator, the holes were put in the USTs when ESSO closed the USTs by filling them with sand.” With a release evident by stained soils and petroleum odor, 110 tons of
contaminated soil was excavated from the former tank pit. Closure soil sample analytical results (TPH GRO: 5,420ppm) indicate a release from the western tank (labeled UST#2). No limit of exaction soil samples were collected to document soil quality post-excavation.

6/22/2004: DEQ sent acknowledgement letter to Mr. Boone for submitting photographs of the site with
ESSO branding. 1/4/2005: DEQ sent a stop funding letter. 2004 – 2006 Guilford County Environmental Health, in partnership with DEQ, sampled wells along Sherfield Rd. Analytical results for several samples collected from the supply well at 8723 Sherfield Rd, showed vacillating contaminant concentrations, predominantly petroleum based. 6/27/2006: Resume funding letter issued. 7/31/2006: Guilford County Environmental Health sent letter to Ms. Dottie Pyrtle of 8723 Sherfield Rd.
stating that her well has been impacted by petroleum-based contamination potentially from Colfax Service Station. Assessment is ongoing between ExxonMobil and Hardin Oil Company, Inc. County officials will continue to sample her well every 3-4 months.
12/5/2006: The submitted monitoring report confirms the continued presence of free product in monitoring well MW1 and dissolved phase contamination in wells MW1D and MW7. No petroleum-type
contamination was detected in the onsite supply well sample. 12/5/2006: A signed affidavit was submitted by Mr. Burch Idol who states he operated the service station under the ownership of Ira Potts. In 1959 the USTs installed at the site were owned by ESSO. When the facility switched to Phillips 66 new USTs were installed. After a disagreement between Mr. Potts and an ESSO rep pertaining to tank removal, the ESSO rep punctured each ESSO tank with a steel rod to leave each tank unusable. 12/12/2006: Funding resume letter sent for Colfax Oil Company, Inc. release incident. 10/8/2013: RP’s consultant sent letter informing of the destruction of monitoring wells MW6 – 8 due to
NCDOT road widening project. 10/7/2014: A monitoring report is submitted detailing the July 29, 2014 groundwater monitoring event. Monitoring wells MW7, MW8, and MW10 were found to be destroyed. Monitoring well MW6 was damaged, but a water level measurement was able to be taken. Free product was again gauged in monitoring well MW1. 2L Standard violations were only reported in monitoring well MW1D.
11/3/2014: Letter sent by NCDEQ to 5 surrounding property requesting property access for supply well sampling. 7/25/2014: Results of the supply well sample, from 8723 Sherfield Rd, report a benzene concentration of 27ppb and diisopropyl ether concentration of 4.8ppb. 8/19/2019: NORR sent requesting a monitoring event and reinstallation of monitoring wells MW7 and MW8. 10/29/2019: A monitoring report was submitting summarizing the sampling of monitoring wells onsite.
No wells were reinstalled as requested in the NORR. The report states free product was removed from MW1 in 2016 and has not since returned. Dissolved phase contaminant concentrations in wells MW1 and MW1D continue to subside.

11/12/2019: An Acknowledgement of Report Receipt was issued, but still requests the reinstallation of
wells MW7 and MW8. 12/9/2019: The RP submitted a letter stating they do not feel they are responsible for the reinstallation of two monitoring wells since the wells were destroyed by the NCDOT. Furthermore, they state that the reinstallation of those wells is for the assessment of the Colfax Service Station release and should be the responsibility of ExxonMobil. 8/26/2021: NORR is sent requesting the completion of a CAP. 12/20/21: Hardin Oil Company is permanently dissolved.
1/6/2022: State Lead Package submitted to the Winston-Salem Interim Regional Supervisor for review. 3/25/2022: State Lead Package submitted to the UST Section Interim Corrective Action Branch Head for
review. Recommendations
1) The LSA (9/15/2000) identifies 25 water supply wells within a 1,000 ft radius. There is disagreement on the number of supply wells in the CSA (04/16/2004) which states 23 water supply wells are located within the search radius. The City of Greensboro currently has water lines available along W. Market St, and a short portion of Bunker Hill Rd to the north and south of W. Market St. An updated receptor survey is needed to clarify discrepancies within these reports and to identify the current status of wells in the area. Additionally, risk reduction by extending water lines to unserved areas should be investigated. It should be noted that analytes found in the supply well at 8723 Sherfield Rd. are similar to those found in MW1, however, no definitive explanation has been made as to the source of this contamination. This well is currently operating with a POE system that is being monitored under the Bernard Allen Fund. 2) CoCs remain at levels greater than the 2L Standard in monitoring well MW1 but have been trending downward. The consultant believes contamination is trapped within the diabase dike which MW1 is
drilled into. Analytical results of surrounding type-II wells MW2, MW3, MW5, MW6 & MW9 have historically been BDL showing no horizontal migration of contamination. These wells, however, are located 60-80 feet from the source area. Low levels of contamination have been documented in the
type-III well (MW1-D) showing minor vertical migration. Active remedial efforts (AFVR) have not shown to be very successful, evidenced by the collection of 61 gallons of liquid on January 19, 2001 and 20 gallons in 1999 from MW1. Future work should include determining the contaminant mass, making a remediation proposal and completing a feasibility study to determine the best course of remediation in the vicinity of MW1 and MW1-D. Additional wells, installed closer to MW1, may be needed to better define the extent of the CoC plume. 3) Analytical results of MW7 from 2003 & 2006 show excessive GCL violations. Monitoring wells MW6, MW7, MW8, & MW10 were lost due to NCDOT road widening. The former RP has since been unwilling to reinstall these wells. Additionally, the RP discouraged additional work in the vicinity of MW7 because they believed this release was attributable ESSO (Exxon). Future work in this area should include the reinstallation of MW7 and installation of additional monitoring wells for horizontal and vertical plume delineation. Horizontal delineation in the southern direction may be inhibited by the presence of W. Market St and Norfolk Southern’s rail line.